Monday, September 27, 2021

To the new Minister of the Environment

 Dear  Mr. Halman, 

In June I wrote to your predecessor about a public health problem with private dumps.  Briefly, your department has no mechanism for notifying people of chemical hazards discovered through monitoring.  I received the attached reply from Deputy Minister Towers, and I take up the issue from there.  

In future, I'd appreciate getting a non-password protected reply.  It would be a convenience to be able to extract quotes, since my 71-year-old fingers are not as deft as they once were.  I am virtually certain that no hacker is interested in our exchanges.,

Since Ms. Towers did not directly answer my questions about the health effects of contaminants from loads of prohibited autofluff, I have to ask again:  Please officially identify the illegally dumped contaminants that I (and others) have been exposed to, which may adversely impact health, so that people may include the information in their personal health records in order to inform doctors decisions.

Do you fish?  I have fished Poole Brook, which runs through my property, for 50 years.  The trout are tasty.  I've eaten dozens. Now I discover the trout are exposed to high levels of Mercury.  The local Peregrine Falcons are in the same food chain. 

I will not file a FOIPOP for information to which I am entitled by right, but I had the  chance to review part of a 2500 page FOIPOP response which raised serious questions about your oversight.  Early on in the FOIPOP there are tables showing Mercury levels above the aquatic life guidelines (page 8) of .0001 mg/l (.1 micrograms/l).  Page 29 shows levels of 0.143 micrograms/l,  sampled September 11, 2018.  The samples were collected after a fire at the dump which started early on September  7.

September 11, 2018Pagemg/lµg/l
Aquatic Life Freshwater Guide-lines60.00010.1
Total Hg 29.143
Later on we have results of testing the autoluff itself.  There are plenty of substances that test over the requested limit, although we don't know who assigned the limits.

March 2017PageResultReporting Limit or Requested Limit mg/kgIn excess

That Toluene result (6000 micrograms/kg) is way, way high (see WHO, page 7).  

It is troubling that the letter of transmittal (page 20) from the dump's paid chemistry expert is dated September 7, 2018 and blames the fire for elevated test results.  The fire hadn't happened yet and the referenced test results are from August 21.  No one on your staff noticed.  Is this just sloppy record keeping?  Was there another fire?  The fact is that on August 21, results were already high.  

On July 15, 2019, nearly a year later (page 2058)  Mr. Frazee writes "Samples collected from the wetland were still quite warm  (31.5C and 23.4C).  This indicates that there is still heat being generated from the site of the fire".  All this time, the community complained about the smell.  Ah, that clean Nova Scotia air!

To focus on an example, Mercury is commonly found in autofluff.  It is a neurotoxin, as Canadians learned from Grassy Narrows.  It is found in freshwater fish.  It accumulates in the human brain and kidneys.  0.143 micrograms is well over the aquatic life guideline - useful in places where fish and fish derivatives are part of the human diet. The US EPA measured total Mercury in 336 watersheds - documenting a mean of 8.22 ng/l or 0.00822 micrograms/l.   The reading of 0.143 micrograms is 17 times higher.  I have never seen a sign along Poole Brook cautioning fishermen.  

You say: "Arlington C&D and Asbestos Disposal Facility was issued a warning for accepting material that was not approved by this department." Assuming the tipping fees are not zero, I am curious: who has the money?  Is it forfeit?  Does AHC&D retain it?  Did they pay tax?  Were the ill-gotten gains distributed to those harmed?  Since you are also Chair of Treasury, this should be easy to answer.

I attach a detailed spreadsheet showing photographs of 106 John Ross deliveries of autofluff to Arlington Heights C&D between January 8,  2019 and November 10, 2020.  The total weight of just these few loads is estimated to be 2,479,000 kgs - 2,420,000 kg after Minister Wilson said the practice had ended.

You say " All information under the control of the department is accessible to the public, subject only to the Freedom of Information and Protection of Privacy (FOIPOP) Act. The goal of the Act is to balance an individual's right to know and an individual's right to privacy. "

I say that your addiction to secrecy must give way to accountability.   Yours is a murderous policy indeed which raises the following issues:
  • Specifically:
    • Taxpayers paid for a comprehensive property ID system.  You know who we are.  Tell us about the poisons you allow in our water.  
    • Why is the testing regime managed by a consultant paid for by the dump owner and not by you?  
    • What is the chain of custody for the samples?
    • The consultant reports in milligrams, the lab in micrograms.  This is confusing and an invitation to error. 
    • The obvious cause of the fire is spilled diesel fuel from the previous day - yet you do not investigate this.  Did you investigate the alarming evidence of mismanagement documented on page 2032?  On page 13 & 14, Jacquelyn Burneau repeats the arson explanation.  Ridiculous.
  • More generally:
    • 'Private Dump" is a concept that invites abuse
    • Why do dump owners get to choose an oversight committee rather than the voiceless community?
    • All test values should be entered on a public database
    • There is reference to the Waste Resource Management DataCall system (page 2307) that not even your staff can access.  Surely you can create a public view that preserves accepted notions of privacy.
    • What is your arms length policy?
    • Why are corporations more valuable than people?
    • Is your record-keeping protocol as chaotic as the FOIPOP suggests?
I look forward to hearing from you.  This letter is public.

Warren Reed

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